Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-07-351 

EPA Docket EPA-HQ-OPPT-2011-0577 

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Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-07-351 

A-002 Initial Review Engineering Report for 

PMN P-07-351 

A-003 Initial Review Exposure Report for 

PMN P-07-351 

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A-001 

Structure Activity Team (SAT) Report

for PMN P-07-351 

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A-002 

Initial Review Engineering Report

for PMN P-07-351 

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P07-0351 ETD IRER.EN1.txt

INITIAL REVIEW ENGINEERING REPORT 

PMN: 07-0351

Post-Focus Draft Revision 1 6/28/2007

ENGINEER: Austin \ DTN

PV (kg/yr): 

SUBMITTER: 

USE: 

 

OTHER USES:

MSDS: Yes Label: No

Gen Eqpt: local exhaust at generation points; chem.

worker goggles; natrual rubber or nitrile rubber gloves.

Respirator: any dust, mist or fume respirator except

single use or disposable respirator or appropriate

particle filter as defined in 42 CFR 84 depending on the

potential for the presensce of oil particle in air and

the filter eficiency neeed.

Health Effects: may cause eye irritation, harmful if

swallowed.

TLV/PEL:

not established.

CRSS (04/16/2017):

Chemical Name: 

S-H20: 0.000003 g/L @

VP: 1.0E-6 torr @

MW: 318.42 %<500 %<1000

Physical State and Misc CRSS Info:

Neat: Solid Mfg: Proc/Form:

 End Use: 

 Submitted data: The PMN material is

a solid with a MP = 170-173 °C by DSC. The PMN material

loses 94% of its mass between 200-380 °C as determined by

TGA. The submitter does not indicate if this is boiling

or decomposition. The DSC measurement does not reach a

high enough temperature to tell the difference. The

submitted IR, 1HNMR, and mass spectra are in agreement

with the structure provided. A UV spectrum was submitted.

 Estimated data: With an input MP = 170 °C, EPI estimated

the following data for the PMN material: BP = 425 °C, VP

= 6.36e-8 torr, WS = 2.9e-3 mg/L, log P = 6.66. As listed

in the prop field in File Registry on STN, ACD labs

estimated the following data for the PMN material: BP =

467.2 °C, VP = 1.86E-08 torr, WS = 0.0010 g/L, log P = 6.

28.

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P07-0351 ETD IRER.EN1.txt

Consumer Use: 

SAT (concerns) (04/17/2007):

Migration to groundwater: Negligible

PBT rating: P2B3T1

Health: 1 Not Required

Eco: 3 Water (All releases to water with a CC = 1ppb)

OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. 

 

 

 

 

 

 

 

 

POLLUTION PREVENTION CONSIDERATIONS:

None.

EXPOSURE-BASED REVIEW: 

INITIAL REVIEW ENGINEERING REPORT 

PMN: 07-0351

MFR

Number of Sites/ Location: 

 Days/yr: 

Basis: Per submission, 

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium.

Output 2: 

to:

from: 

basis: 

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P07-0351 ETD IRER.EN1.txt

n

Output 2: 

to: 

from: 

basis: 

 

 

Conservative: 

to: 

from:

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

Exposure to 

Upper Bound: 

Number of workers (all sites) with inhalation exposure: 

Basis:

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit

 or data not specific to industry): Yes

2)a) Exposure level > 1 mg/day? Yes

 OR

 b) Hazard Rating for health of 2 or greater? 1 No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:

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P07-0351 ETD IRER.EN1.txt

INITIAL REVIEW ENGINEERING REPORT 

PMN: 07-0351

PROC1: 

Number of Sites/ Location: 

 Days/yr: 

Basis: Per submission, 

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium.

Output 2: 

to: 

from:

basis:

Output 2: 

to: 

from:

basis: 

 

Conservative: 

to: 

from:

basis: 

 

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

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P07-0351 ETD IRER.EN1.txt

Basis:

Inhalation:

negligible (VP < 0.001 torr )

Exposure to 

Upper Bound: 

Number of workers (all sites) with inhalation exposure: 

Basis:

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit

 or data not specific to industry): Yes

2)a) Exposure level > 1 mg/day? Yes

 OR

 b) Hazard Rating for health of 2 or greater? 1 No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:

Exposure to 

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:

Exposure to 

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:

 

INITIAL REVIEW ENGINEERING REPORT 

PMN: 07-0351

PROC2: 

Number of Sites/ Location: 

 

Days/yr: 

Basis: Per submission, 

Process Description:

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P07-0351 ETD IRER.EN1.txt

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium.

Output 2: 

to: Incineration

from: 

basis: 

Conservative: 

to: 

from:

basis: 

 

Output 2: 

to: 

from: 

basis:

High End: 

to: 

from:

basis:

 

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

negligible (VP < 0.001 torr )

Dermal:

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P07-0351 ETD IRER.EN1.txt

Exposure to 

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:

Exposure to 

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:

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A-003 

Initial Review Exposure Report

for PMN P-07-351 

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